The Appraisal Modernization Act requires the Federal Housing Finance Agency (the Agency) to build and publish a searchable, appraisal-level public use file of residential appraisal data supplied by Fannie Mae, Freddie Mac, FHA, USDA, and VA. The statute prescribes detailed data fields, deadlines for legacy and ongoing data transfers, and a rulemaking pathway that lets the Agency limit certain disclosures only after notice and comment.
The bill also amends the Truth in Lending Act to give consumers a formal reconsideration-of-value process: creditors must review appraisals, provide a standardized disclosure and submission form, accept one consumer-initiated reconsideration (with up to five comparable properties), and, where material deficiencies or discrimination are suspected, order a subsequent appraisal at the creditor’s expense and refer reports to appraiser licensing or enforcement authorities. The law creates new compliance, privacy, and operational trade-offs for lenders, appraisal management companies, appraisers, and the Agency itself.
At a Glance
What It Does
Mandates that specified Federal housing agencies deliver legacy (2017–enactment) and ongoing appraisal-level data to the Agency, which must publish a searchable, downloadable public use file and update it quarterly. Amends TILA to require creditors to operate a consumer-initiated reconsideration-of-value process and to order or fund subsequent appraisals when deficiencies or discrimination are suspected.
Who It Affects
Fannie Mae, Freddie Mac, FHA, USDA, VA, the Federal Housing Finance Agency (the Agency/Director), federally regulated creditors and mortgage lenders, appraisal management companies (AMCs), individual appraisers (credential and ID reporting), state appraiser regulators, fair-lending enforcers, and mortgage applicants/borrowers.
Why It Matters
This bill creates the first large-scale, federal appraisal-level public dataset and a statutory pathway for consumers to challenge valuations—tools that could materially change fair-lending enforcement, appraisal oversight, and compliance workflows while raising privacy and operational-cost questions for industry and regulators.
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What This Bill Actually Does
The bill does two distinct but related things. First, it inserts a new Public Appraisal Database section into the Federal Housing Enterprises Safety and Soundness Act.
That section directs the major federal housing program participants (Fannie Mae, Freddie Mac, FHA, USDA, VA) to hand over appraisal data they collected both historically (starting January 1, 2017) and going forward. The Agency’s Director must assemble those data into an appraisal-level public use file that is searchable and downloadable and update it quarterly.
Second, the bill amends the Truth in Lending Act to create a consumer right to request a reconsideration of value or a subsequent appraisal. Creditors must perform an initial appraisal review, give borrowers a standardized written disclosure explaining how to request a reconsideration, accept one consumer-initiated request (before closing or within 60 days of denial), and communicate with appraisers using standardized formats.
Consumers may submit supporting materials including up to five alternative comparable properties.If an appraisal contains material deficiencies that the original appraiser does not correct, or if the creditor has reason to believe an appraisal reflects discrimination, the creditor must order a subsequent appraisal at its expense and forward the original report and the creditor’s findings to the appropriate licensing or enforcement authority. Creditors must keep all communications and documentation related to the reconsideration or subsequent appraisal for seven years.
Both the Agency (for the database) and the Federal Housing Finance Agency (for the TILA changes) must complete notice-and-comment rulemaking and issue final rules and guidance within the statute’s one-year windows to operationalize the requirements.
The Five Things You Need to Know
The bill requires Fannie Mae, Freddie Mac, FHA, USDA, and VA to provide legacy appraisal data (from Jan 1, 2017 to enactment) to the Agency within 180 days of enactment.
The Agency must publish a searchable, downloadable appraisal-level public use file within 2 years and update that public database on a quarterly basis thereafter.
The statute mandates highly granular appraisal fields be disclosed in the public file—appraiser credential and ID, scope and date of inspection, full comparable-property data and adjustments, market metrics, unit and condition ratings, and the Universal Loan Identifier and borrower race/ethnicity as provided by the agencies.
A consumer may submit one reconsideration-of-value request (before loan closing or within 60 days of denial) using a standardized form and include up to five alternative comparable properties; creditors must respond and can obtain clarification from the consumer if needed.
Creditors must retain all documentation related to a reconsideration or subsequent appraisal for 7 years, and must forward appraisal reports and creditor findings to state licensing boards or enforcement agencies; if discrimination is finally determined, appraisers must reimburse the creditor for the cost of the subsequent appraisal.
Section-by-Section Breakdown
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Purpose and Definitions for the Public Appraisal Database
Sets out the statutory purpose—to provide appraisal data to the public and governments to evaluate whether valuation professionals serve the market efficiently and consistently—and defines key terms used throughout the new section (application, dwelling, financial institution, mortgage loan). These definitions frame the scope of data the Agency will collect and publish and anchor later deadlines and reporting obligations.
Agency Appraisal Data Sharing: Legacy and Ongoing Transfers
Requires the specified federal housing entities to deliver two tranches of data: (1) legacy appraisal data covering Jan 1, 2017 through enactment within 180 days; and (2) modernized appraisal data covering each prior quarter on a rolling quarterly basis beginning within 1 year. Each transfer must include the appraisal data and a set of loan- and borrower-level identifiers (census tract, agency loan ID, Universal Loan Identifier, loan purpose, owner-occupancy indicator, acquiring agency, and race/ethnicity where provided). Those deadlines create a compressed operational timeline for agencies and the entities that supply data.
Public Searchable Database and Required Data Fields
Directs the Director to publish a searchable, downloadable appraisal-level public use file within 2 years and update it quarterly. The statute prescribes extensive, itemized fields to be disclosed—assignment metadata, full subject property descriptors, market and listing analytics, project-level condo/HOA data, every comparable’s detailed characteristics and adjustments, reconciliation and valuation conclusions, and certain loan and borrower identifiers. This level of granularity aims to make appraisal reasoning auditable but raises practical questions about data quality, standardization, and privacy.
Privacy Discretion, Enforcement Access, and Rulemaking
Gives the Agency authority to modify publicly available data after notice-and-comment if unmodified releases create unjustified privacy risks. At the same time, it requires the Agency to provide unredacted data on request to a broad list of enforcement and supervisory bodies—Executive agencies, the Federal Reserve, OCC, FDIC, NCUA, Appraisal Subcommittee, CFPB, and State AGs and appraiser regulators—so regulators can investigate and enforce. The Agency must adopt a final rule and guidance within one year of enactment to implement the database program.
Consumer Right to Reconsideration of Value — Disclosure and Process
Adds a consumer-facing reconsideration-of-value process: creditors must perform an initial appraisal review, provide standardized disclosures and a submission form at application and upon delivery of the appraisal, accept one consumer request prior to closing or within 60 days of denial, and may seek clarifying information from the consumer. The statutory submission format requires basic borrower and appraisal identifiers plus a justification and up to five alternate comparables—standardization intended to reduce variability in requests and help appraisers respond consistently.
Subsequent Appraisals, Referrals, and Remedies
If a creditor finds material deficiencies not remedied by the original appraiser, or has reason to believe discrimination occurred, the creditor must order a subsequent appraisal at its own cost and forward the original appraisal and the creditor’s summary to the relevant licensing or enforcement authority (and to law enforcement if discrimination is suspected). The statute defines ‘reason to believe’ broadly to include review of files, statistics, and credible observations, but clarifies that it does not require a final legal determination before acting. If an enforcement agency ultimately finds discrimination, the appraiser must reimburse the creditor for the subsequent appraisal.
Recordkeeping and Regulatory Implementation
Mandates that creditors retain all documents and communications related to reconsiderations and subsequent appraisals for seven years. It also requires the FHFA to complete a notice-and-comment rulemaking and issue final rules and guidance to operationalize the new reconsideration-of-value process within one year, aligning statutory deadlines for implementation and leaving significant detail to agencies’ rulemakings.
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Explore Housing in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Fair-lending enforcers and civil-rights researchers: The public, appraisal-level dataset plus borrower identifiers gives enforcement agencies and researchers empirical tools to detect appraisal bias, discriminatory patterns, and market disparities that are difficult to assess from aggregated or proprietary records.
- Consumers and borrowers challenging appraisals: The statutory reconsideration right, standardized submission form, and guaranteed creditor review give borrowers a formal, documented pathway to raise appraisal deficiencies and obtain a funded subsequent appraisal when problems are credible.
- Local housing policymakers and market analysts: Detailed market metrics (comparable adjustments, days on market, list/sale price ranges) will support local housing studies, valuations research, and policy design to address appraisal-related inequities.
- State appraiser licensing boards and professional investigators: Required forwarding of appraisal reports and creditor summaries creates more timely referrals and richer evidence packages for disciplinary or corrective action.
Who Bears the Cost
- Creditors and mortgage lenders: Must implement standardized disclosure and intake processes, perform initial appraisal reviews, fund subsequent appraisals when required, and retain documentation for seven years—raising operational costs and potential origination delays.
- Appraisers and appraisal management companies (AMCs): Face expanded reporting expectations, greater scrutiny from public datasets, higher risk of referrals/discipline, and potential reputational or business impacts if many appraisals are challenged.
- The Agency/FHFA and contributing agencies (FHA, USDA, VA): Must build, host, and maintain a large, granular public database, validate and standardize incoming data, and conduct rulemaking within statutory timeframes—requiring budget, systems, and staffing.
- Borrower privacy interests: Publication of granular property- and borrower-linked appraisal information creates concrete privacy risks for mortgage applicants and occupants, even with the Agency’s limited authority to modify releases.
Key Issues
The Core Tension
The central dilemma is transparency versus privacy and operational burden: making appraisals public and easy to challenge empowers oversight and fair-lending enforcement but imposes heavy compliance, data-standardization, and privacy costs on lenders, appraisers, and the federal agencies that must assemble and police the data—and those costs may, in turn, affect appraisal availability, speed, and professional behavior.
The bill trades maximal transparency for practical and privacy complications. Publishing appraisal-level records with borrower and loan identifiers will materially improve the ability to detect patterns of bias, but the statute leaves significant choices about what to redact, how to standardize heterogeneous appraisal formats, and how to correct poor-quality or inconsistent data.
The Agency’s authority to modify disclosures after notice-and-comment is a safety valve, but using it will require careful balancing and likely extensive rulemaking and defensible methodologies for deletion or aggregation.
The reconsideration-of-value regime creates an asymmetric workflow risk. Creditors must fund subsequent appraisals when deficiencies or discrimination are suspected; this protects consumers but risks increased origination costs, longer closing times, and potential gaming of the process.
The statutory definition of ‘unacceptable appraisal practice’ mixes observable data problems (inaccurate comparables) with qualitative judgments (unsupported terms, subjective market commentary), which may produce many borderline disputes and put appraisers in a defensive posture. Finally, the statute grants broad enforcement access to unredacted data, increasing the likelihood of multi-jurisdictional investigations and a patchwork of supervisory interpretations that could vary by state or agency.
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